Coal Production Is ‘Manufacture’, Not Service; CESTAT Quashes Rs.352 Crore Service Tax Demand

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Coal Production Is ‘Manufacture’, Not Service; CESTAT Quashes Rs.352 Crore Service Tax Demand

Indirect Taxes

Published on

17/04/2026

By Mariya Paliwala

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The Customs, Excise and Service Tax Appellate Tribunal (CESTAT), Kolkata has held that activities relating to extraction, processing, and dispatch of coal amount to “manufacture” and not a taxable service, thereby setting aside a massive service tax demand of over ₹352 crore raised against M/s EMTA Coal Limited. The bench of Ashok Jindal (Judicial Member)…

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Mariya Paliwala https://www.jurishour.in/

Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

Coal Production Is ‘Manufacture’, Not Service; CESTAT Quashes Rs.352 Crore Service Tax Demand

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